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Carlos Arévalo published an article in the Illinois State Bar Association newsletter on local government law. In the article he discusses a case in which the United States Court of Appeals for the Second Circuit found that police officials were not immune from liability for an officer’s claim that she was fired for her First Amendment speech. In the case, the fired officer researched and made a document that covered questionable overtime procedures, which drew scrutiny when it was made public. The officer was later fired on the grounds of “insubordination.” The Second District rejected the defendants’ qualified immunity argument noting that a public employee’s speech as a citizen on a matter of public concern has First Amendment protection.